This privacy notice describes how PRIME Commitment Limited (“PRIME” “we” or “us”) collects and processes personal information about you, how we use and protect this information, and your rights in relation to this information.

This privacy notice applies to all personal information we collect or process about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.

1. Personal information we use
We will collect personal information from you directly (e.g. when you contact us) and also from other sources described below.

1.1 Information we collect directly from you
The categories of information that we collect directly from you are:

1.2 Information we collect from other sources:
We collect information about you from other sources:

(a) PRIME members
(b) Rare Recruitment Limited

The categories of information that we collect about you from these sources are:

(a) Personal details (e.g. name, date of birth, gender)
(b) Contact details (e.g. home postcode)
(c) Unique identification code
(d) Educational history (e.g. school attended, grades and start/finish dates)
(e) Information about your socioeconomic status, including whether your parents/guardians attended university, whether you hold refugee or asylum seeker status, whether you are a parent or registered carer, whether you have free school meals, whether you have been in local authority care, and whether you undertook paid work during school or university term time

Some of the categories of information that we collect are special categories of personal data (also known as sensitive personal information). In particular, we process personal information that relates to your ethnic origin.

2. How we use your personal information and the basis on which we use it
We use your personal information to:

(a) further improve access to the legal profession by conducting statistical analysis to understand, for example, the breakdown of participants on PRIME programmes by region, the percentage of social mobility students attending PRIME programmes and the breakdown of participants’ background (e.g. how many were in receipt of free school meals)

(b) communicate with you and respond to your enquiries and feedback.

We must have a legal basis to process your personal information. In most cases the legal basis will be to meet our legitimate interests, for example to conduct statistical analysis to support our goal of providing fair access to the legal profession and monitoring our progress in achieving this. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. For more information about the balancing test that we carry out to process your personal information to meet our legitimate interests, please contact us at the details below.

We may obtain your consent and use certain types of personal information when we are required to do so by law (for example, when we use your personal information for direct marketing purposes or when we process sensitive personal information such as information about your ethnic origin). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.

3. Your rights over your personal information
You have certain rights regarding your personal information, subject to local law. These include the following rights to:

access your personal information

rectify the information we hold about you

erase your personal information

restrict our use of your personal information

object to our use of your personal information

receive your personal information in a usable electronic format and transmit it to a third party (right to data portability)

lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights, please contact us at the details below.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

We will contact you if we need additional information from you in order to honour your requests.

4. Information Sharing
We may share your personal information with third parties under the following circumstances:

PRIME members. We share your personal information with PRIME members to ensure that all participants in PRIME programmes come from social mobility backgrounds where access to the legal profession is particularly difficult.

Rare Recruitment Limited. We share your personal information with Rare Recruitment Limited to enable them to conduct statistical analysis that helps us understand if there are ways in which we could further improve access to the legal profession.

Law enforcement agencies, courts, regulators and government authorities. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.

5. Information Security and Storage
We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.

6. Retention
We will keep your personal information for as long as we have a relationship with you, and for a period of 6 months thereafter. We will only retain your personal information after this time if we are required to do so to comply with the law, or if there are outstanding claims or complaints that will reasonably require your personal information to be retained.

7. Contact Us
PRIME Commitment Limited is the controller responsible for the personal information we collect and process.If you have questions or concerns regarding the way in which your personal information has been used, please contact Clare Harris at clare.harris@hoganlovells.com.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner’s Office.

8. Changes to the Policy
You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time.

If we change this privacy notice, we will notify you of the changes. Where changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).